Southwest Florida Center For Hearing and Balance Privacy Policy

Last Updated Effective: February 2024

Information protected by HIPAA will be governed by our practice’s HIPAA Notice of Privacy Practices, which is available upon request.

This privacy notice discloses the privacy practices for Southwest Florida Center For Hearing and Balance with respect to non-HIPAA-protected information. 

By using this website, you are agreeing to the terms of this Privacy Policy.  

If you are a California resident, please see our California Privacy Rights Section below.

Information We Collect

Information you Voluntarily Provide: We may receive personal information when you interact with our Website or our services. For example, when you:

• Request information regarding our practice;
• Participate in surveys, sweepstakes or other promotional activities online or in any other venue (including on any social media platform);
• Subscribe to our newsletters, programs, promotional emails or other materials;
• Apply for a job, submit your resume/CV or create a candidate profile; or
• Contact us with your questions/comments.

Note that we may also receive information about you from third party sources, such as your family members.

Your interactions with our website and emails: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the website and our services, to improve the content and performance of our website and services, to manage your online shopping cart, and to track users’ movements around the website. We may also link this automatically-collected data to personal information. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that we may use on our website please see our section regarding Cookies below.

Disclosing Personal Information

Your personal information may also be shared with:

• Parties who support our practice, such as technical support, delivery services, professional advisors as well as web-hosting providers, analytics providers, customer-relationship management software providers and other information technology providers;
• Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues; and
• To our affiliated entities and in connection with the sale, assignment or other transfer of our practice.

Except as described above, we will not disclose your personal information to third parties for their own marketing purposes without your consent.

Choices Regarding Our Collection and Use of Your Information

We may offer you choices regarding the information we collect and how that information is used and shared. These choices may include the ability to access, update or delete information that you have provided to us or information that we have collected through your use of our website. They may also include the ability to opt-out of receiving notifications, promotions, offers or other advertising from us. To inquire about making any of these requests please contact us below. Note that if at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

How We Secure Your Personal Information

We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline.

Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only individuals who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

Links to Other Web Sites

You should be aware that when you are on the website you could be directed to other sites beyond our control. These other websites may send their own cookies to you, independently collect data or solicit personal information and may or may not have their own published privacy policies. If you visit a website that is linked to one of our websites, you should consult that site’s privacy policy before providing any personal information. Please note that we are not responsible for the privacy practices of third parties.

Collection and Use of Children’s Personal Information

Our website is directed to people who are at least 13 years old or older. If any parent, guardian or other responsible adult becomes aware that we have collected personal information from a child under the age of 13, please contact us below.

Cookie Guide

As with many websites, our website and services (such as our email updates) use a standard technology called a “cookie” and other similar technologies (such as, pixels, tags and web beacons), which are small data files that are transferred to your computer when you use our Website and services. These technologies automatically identify your browser whenever you interact with our website and services.

There are different types of cookies and other technologies used on our website and services, notably:

“Session cookies” – These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).

“Persistent cookies” – These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.

“Web Beacons/Pixels” – Some of our web pages and emails may also contain small electronic images known as web beacons, tags, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email offers.

We use cookies and other tracking technologies to:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into and manage your account and to place orders.
• Analytical/performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website and services when they are using it. This helps us to improve the way our website and services work, for example, by ensuring that users are finding what they are looking for easily. We also may use these tools to help deliver analytics to our Practice partners to give them insight into the Practice website.
• Functionality cookies. These are used to recognize you when you return to our website and services. This enables us to personalize our content for you, greet you by name and remember your preferences.
• Advertising/Targeting cookies. These cookies record your visit to our website and services, the pages you have visited and the links you have followed. We will use this information to make our website and services and the advertising displayed on it and on third party sites more relevant to your interests. We may also share this information with third parties for this purpose.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from our website you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It’s also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser’s “Help” function or alternatively, you can visit https://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Third-Party Ad Serving & Audience and Traffic Measurement Services

The website may use third party network advertisers to serve advertisements you may see. Network advertisers are third parties that display advertisements based on your visits to the Site and other websites you have visited. Third-party ad serving enables us to target advertisements to you for products you might be interested in.

Our website is in compliance with the Ad Choices Self-Regulatory Program for Online Behavioral Advertising. The goal of Ad Choices is to provide you with information about how online advertising works and the choices you have.

You may visit the https://www.aboutads.info/choices page to learn more about online behavioral advertising and to see your opt-out choices from companies that are participants in the Self-Regulatory Program for Online Behavioral Advertising.

Please note that if you choose to opt out, you will still see ads, but these ads will not be customized based on your interests generated from your visits over time and across different websites. In addition, the preferences you select on the https://www.aboutads.info/choices page may not apply to mobile devices. Due to the differences between using apps and websites on mobile devices, opt-outs will need to be set for both browsers and apps.

Do-Not-Track

Some browsers have incorporated a Do-Not-Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our website.

Social Media & Features

Our website may include social media features, including the Facebook “Like” button and Twitter “Follow” button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

Users Outside the United States

Southwest Florida Center For Hearing and Balance is located in the United States. The website is directed solely towards users who reside in the United States. If you choose to use the website from outside the United States, you are consenting to the collection, storage, processing, and transfer of your information in and to the United States, pursuant to the laws of the United States.

Notwithstanding the forgoing, we will honor the following requests from users:

• If the processing of personal data is based on your consent, the right to withdraw consent for future processing of that data.
• The right to request from us access to and rectification of your personal data.
• Subject to reasonable limitations, the right to request restriction of the processing of your personal information.
• Subject to reasonable limitations, the right to request erasure of your personal data.

You may contact us using any of the methods described in the “Contacting Us” section of this Privacy Policy below to exercise these rights. We may require you to verify your identity to exercise any of these rights.

Terms Applicable To California Residents

This Privacy Policy for California Residents supplements the information contained in the Privacy Policy on this page, and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and as amended and effective January 1, 2023, the California Privacy Rights Act (CPRA). Any terms defined in the CCPA and CPRA have the same meaning when used in this Policy. The CCPA and CPRA are collectively referred to as the “CCPA” for purposes of this Notice.

To the extent allowed by law, this policy does not cover certain written or oral communications or information obtained in the course of a business-to-business relationship (“B2B Information”).

Information We Collect

We collect information from individuals that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope that may be covered by additional laws and regulations such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Highly Sensitive Information

Certain of the categories listed above represent “Highly Sensitive Information” as such term is defined in the CPRA. We do not collect, use, share or store Highly Sensitive Information except for purposes of performing our services, providing our products or for such purposes as requested by you. For example, we may collect Highly Sensitive Information such as credit card or financial information for purposes of a transaction involving our products or services. We may also use Highly Sensitive Information to conduct background checks or for other purposes authorized by yourself. We do not share Highly Sensitive Information with third parties unless they are necessary to assist us in performing the services requested. We do not sell Highly Sensitive Information to any third-parties. We also may collect Highly Sensitive Information in an employment context if you are applying for a position with our company or are currently or formerly employed by our company. For more information regarding our Highly Sensitive Information in an employment context please see below “CCPA Notice at Collection for California Employees and Applicants”.

Retention Periods for Highly Sensitive Information

Pursuant to the requirements of the CPRA [Specifically, Cal. Civ. Code § 1798.100(a)(3)], we would like to inform you that we will only keep personal information and Highly Sensitive Information for so long as it is reasonably necessary to do so in accordance with the provisions of the CPRA and our internal policies. If you are concerned regarding our retention of your personal information including Highly Sensitive Information you may request deletion of such information in accordance with the provisions of this Notice in the manner set forth below. We may be required by law to retain certain information including your personal information and Highly Sensitive Information, or may choose to retain certain information for a legitimate business purpose.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to fill out a contact form, we will use that personal information to respond to your inquiry. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website and services.
• To create, maintain, customize, and secure your account with us, if applicable.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud, if applicable.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users and consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Southwest Florida Center For Hearing and Balance has disclosed personal information for a business purpose to MedPB.

We do not sell personal information. In the preceding twelve (12) months, Southwest Florida Center For Hearing and Balance  has not sold personal information. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for B2B personal information.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

• Calling us at 239-946-5409 or using the form below.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, please provide written confirmation of your authority to act on behalf of the California resident on whose behalf you are making a request.

You may also make a request to know or delete on behalf of your child by contacting us as set forth above.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

In order to verify your request to access or delete your data, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.

When we receive your request to exercise your rights under the CCPA: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including Personal Information; and (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.

Personal Information Sales Opt-Out and Opt-In Rights

In certain circumstances our use of Cookies may be deemed to be a ‘sale’ under California law.  You have the right to opt-out of our ‘sale’ of your internet collected data when you browse our website.  To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us using the info at the bottom of this page.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by sending us an email requesting to opt back in.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

 Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. We do not currently provide any financial incentives.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information at the bottom of this page.

B2B Information

We currently collect certain business to business (B2B) information from vendors, customers, service providers and suppliers in order to conduct our business. This information usually includes e-mail addresses, business addresses, phone numbers, tax information such as EIN and may include Highly Sensitive Information such as credit cards or financial bank information such as account numbers. We do not share this information with third-parties except to perform services or transactions requested by our B2B contacts.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or services you purchase from us.
• Indirectly from you. For example, from observing your actions on our Website.

CCPA Notice at Collection for California Employees and Applicants

We collect and use Personal Information for human resources, employment, benefits administration, health and safety, and business-related purposes and to be in legal compliance. Below are the categories of Personal Information we collect and the purposes for which we intend to use this information:

• Identifying information, such as your full name, gender, date of birth, and signature.
• Demographic data, such as race, ethnic origin, marital status, disability, and veteran or military status.
• Contact information, such as your home address, telephone numbers, email addresses, and emergency contact information.
• Dependent’s or other individual’s information, such as their full name, address, date of birth, and Social Security numbers (SSN).
• National identifiers, such as SSN, passport and visa information, and immigration status and documentation.
• Educational and professional background, such as your work history, academic and professional qualifications, educational records, references, and interview notes.
• Employment details, such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.
• Financial information, such as banking details, tax information, payroll information, and withholdings.
• Health and Safety information, such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information.
• Information Systems (IS) information, such as your search history, browsing history, login information, and IP addresses on the Company’s information systems and networks.
• Sensory or surveillance information, such as COVID-19 related temperature checks and call monitoring and video surveillance.
• Profile or summary about an applicant/employee’s preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.

The Company collects Personal Information to use or disclose as appropriate to:

• Comply with all applicable laws and regulations.
• Recruit and evaluate job applicants and candidates for employment.
• Conduct background checks.
• Manage your employment relationship with us, including for:
  • onboarding processes;
  • timekeeping, payroll, and expense report administration;
  • employee benefits administration;
  • employee training and development requirements;
  • the creation, maintenance, and security of your online employee accounts;
  • reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
  • workers’ compensation claims management;
  • employee job performance, including goals and performance reviews,
    promotions, discipline, and termination; and
  • other human resources purposes.
• Manage and monitor employee access to company facilities, equipment, and systems.
• Conduct internal audits and workplace investigations.
• Investigate and enforce compliance with and potential breaches of Company policies and procedures.
• Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company.
• Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance.
• Perform workforce analytics, data analytics, and benchmarking.
• Administer and maintain the Company’s operations, including for safety purposes.
• For client marketing purposes.
• Exercise or defend the legal rights of the Company and its employees.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

By Telephone: 239-946-5409

By Regular Mail:

Southwest Florida Center For Hearing and Balance
7780 Cambridge Manor Place, Suite C,
Fort Myers, FL, 33907

Terms Applicable To Canadian Residents

Right of Access. Under Canadian privacy laws you have the right:

• To be informed of the existence, use and disclosures of your Personal Information;
• To receive an account of the uses that have been made of your Personal Information by us and any third parties to whom it has been disclosed;
• To be given access to your Personal Information; and
• To challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.

We may require that you provide information verifying your identity before we provide this requested information to you. To obtain such information, please contact us.

Legal Disclosures and Lawful Requests. We and our service providers and affiliates may disclose your Personal Information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Changes to This Privacy Statement

We will occasionally update this Privacy Policy. If we make changes to this Privacy Policy or make any material changes to how we use your personal information, we will revise this Privacy Policy to reflect such changes and revise this Privacy Policy’s effective date, included at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we are using and protecting your personal information.